"2021 The Year in Review – Tax Law"

Renesha Fountain article on "The Year in Review – Tax Law"

Renesha Fountain, senior counsel at Chamberlain Hrdlicka, contributed the Tax Law Update for the “2021: Year in Review” January 2022 issue of Texas Bar Journal. Fountain maintains an active practice in tax planning and tax controversy and represents clients in disputes with the IRS and state and local taxing authorities. 

In the article, Fountain discussed the ongoing impact of the COVID-19 pandemic on taxpayers, the IRS and U.S. Tax Court. She provided an overview of the Taxpayer Relief Initiative, which was announced by the IRS in November 2020 and provided tax relief such as giving eligible taxpayers with short-term payment plans more time to pay.

“The IRS is more open to working with taxpayers who are temporarily unable to satisfy the payment terms of an accepted offer in compromise,” said Fountain. “The IRS will automatically include additional tax balances in existing installment agreements for individuals and businesses that are no longer operating.”

Fountain also discussed the status of U.S. Tax Court filings in 2021 as well as the revocation or denial of passports, as a result of taxpayers’ accounts being declared as ‘seriously delinquent tax debt’ under Internal Revenue Code Section 7345. In Rowen v. Commissioner, the tax court held that Section 7345 does not prohibit international travel and thus does not violate the due process clause of the Fifth Amendment or the Universal Declaration of Human Rights.